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2014 (11) TMI 722 - AT - Income TaxDetermination of ALP – International transaction – Assessee is carrying on the business of providing services for in-bound, out-bound and local travels - Held that:- Following the decision in Destination of the World (Subcontinent) (P.) Ltd. Versus Assistant Commissioner of Income-tax, Circle 10(1), New Delhi [2011 (7) TMI 576 - ITAT, DELHI] - the assessee was justified in undertaking internal comparison on standalone basis by placing on record working of operative profit margin from international transactions with AEs and transactions with uncontrolled parties undertaken in similar functional and economic scenario - Such internal comparison is valid in all the methods - TNMM is the most appropriate method deserves to be upheld – earlier the matter has been restored the issue to verify the calculation as they had not been vetted either by the AO or by the CIT(A) – the order is upheld – Decided against revenue.
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